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Partner & Vendor Policies

Supplier & Vendor Policy · Anti-Bribery & Corruption Policy — SkyNet X Solutions LLC FZ · Meydan Free Zone, Dubai, UAE · Licence No. 2531132.01 


Effective Date: April 2025

Last Updated: March 2026


Compliance Officer: compliance@snxs.ae


This page applies to all suppliers, vendors, contractors, agents, and third parties engaged by or working with SNXS.


Section A — Supplier & Vendor Policy

Section B — Anti-Bribery & Corruption Policy


Both policies are incorporated by reference into all SNXS supplier contracts, purchase orders, and engagement letters. Separate policies govern Creators Pad at app.snxs.ae.



Section A — Supplier & Vendor Policy



1. Purpose


SNXS works with a broad ecosystem of suppliers across event production, marketing, content creation, logistics, media, technology, and creative services. This Policy sets the eligibility standards, required documentation, ethical expectations, AML and sanctions obligations, and commercial terms that all suppliers must satisfy before and throughout any engagement with SNXS.



2. Supplier Eligibility


To be eligible to supply SNXS, all suppliers must:


• Hold a valid trade or business licence in their country of operation (not expired at time of engagement).

• Not be listed on any UAE, UN, OFAC, or EU sanctions, terrorist designation, or prohibited persons list.

• Comply with all applicable laws in their jurisdiction and under UAE law.

• Hold a UAE Tax Registration Number (TRN) if VAT-registered.

• Not operate in or be beneficially associated with FATF Black List jurisdictions (currently: Iran, North Korea, Myanmar).

• Demonstrate financial stability and a relevant professional track record proportionate to the scope of engagement.

• Not be subject to any unresolved regulatory investigation, insolvency proceeding, or material legal dispute that could affect ability to perform.



3. Required Onboarding Documents


Before first engagement, all suppliers must provide:


1. Valid trade licence or business registration certificate.

2. Certificate of incorporation or equivalent constitutional document.

3. UBO declaration identifying all individuals owning or controlling 25% or more of the entity, per UAE Cabinet Resolution No. 58 of 2020, with valid government-issued photo ID for each UBO.

4. Valid government-issued photo ID (Emirates ID or passport) for each authorised signatory.

5. Bank account details on official company letterhead (for payment verification).

6. UAE TRN certificate, if VAT-registered.

7. Signed acknowledgement of this Supplier & Vendor Policy.

8. Signed Non-Disclosure Agreement where the engagement involves access to confidential client, event, campaign, or commercial information.


SNXS may request additional documents based on the nature and value of the engagement or the outcome of risk assessment.


All KYB records are retained for a minimum of 5 years from the end of the business relationship, in accordance with UAE AML law. KYB is reviewed by the Compliance Officer before contract execution.



4. AML and Sanctions Compliance


All suppliers confirm at onboarding, and annually thereafter, that they are not subject to, and have no known connection with, any sanctions programme, money laundering activity, terrorist financing, organised crime, or corruption.


Suppliers must also notify SNXS immediately if they become subject to any investigation, regulatory action, sanctions listing, adverse legal proceeding, or insolvency after onboarding.


SNXS screens all suppliers against applicable sanctions databases at onboarding and conducts periodic rescreening. Any confirmed positive match results in immediate contract termination without compensation and, where required, a SAR filing with the UAE FIU.



5. Ethical Standards


All suppliers must adhere to the following throughout their engagement with SNXS:


• Zero tolerance for bribery, corruption, kickbacks, or facilitation payments. See Section B of this page.

• Full compliance with UAE Federal Decree-Law No. 33 of 2021 on Labour Law. No forced, compulsory, or child labour. All workers engaged by the supplier must hold valid UAE work authorisation where required.

• Protection of SNXS and client confidential information and intellectual property in accordance with UAE IP law.

• Honest and accurate representation of capabilities, credentials, pricing, subcontracting arrangements, and organisational capacity.

• Environmentally responsible practices where operationally applicable.

• These ethical standards apply equally to any subcontractors engaged by the supplier to deliver SNXS-related work.



6. Procurement and Purchase Orders


Engagements with a total value above AED 10,000 are subject to SNXS's internal competitive sourcing review.


All engagements must be formalised through a written Purchase Order issued by an authorised SNXS representative, or a signed Service Agreement or engagement letter.


The following are not binding procurement authorisations:

• Verbal agreements (in any setting or meeting).

• WhatsApp, SMS, or messaging app confirmations.

• Informal emails without a formal PO or agreement reference.


Invoices submitted without a corresponding SNXS Purchase Order reference number may be returned to the supplier for correction.



7. Payment Terms


Standard payment terms: Net 30 days from SNXS's receipt of a valid, fully compliant UAE tax invoice meeting all requirements of the SNXS Invoice Policy (snxs.ae/policies/legal-and-commercial-terms).


A late payment fee of 1.5% per month applies to SNXS overdue balances in accordance with UAE Federal Law No. 2 of 2022.


SNXS may withhold payment where the invoice is non-compliant, a performance dispute or quality issue is active, or the supplier is under compliance review.


SNXS does not make cash payments to suppliers. All supplier payments are made exclusively by bank transfer to the supplier's verified, registered business bank account as provided at KYB onboarding.



8. Performance Standards


Suppliers must deliver services to the agreed scope, quality specifications, and timeline. Where any risk to delivery arises, the supplier must notify SNXS in writing at the earliest opportunity.


Suppliers are responsible for ensuring that all their personnel, subcontractors, and equipment comply with applicable health, safety, and legal standards, including any venue or event-specific requirements communicated by SNXS.



9. Insurance


Suppliers engaged for on-site event services, physical production, AV or staging, or any activity involving public interaction must hold adequate public liability insurance and professional indemnity insurance where applicable. SNXS may request evidence of valid insurance certificates before commencement of engagement.



10. Termination


For convenience: 14 calendar days' written notice. SNXS will pay for undisputed services rendered up to the termination date.


Immediately and without notice or compensation in cases of:

• Confirmed sanctions match or prohibited party listing.

• Fraud, misrepresentation, or falsification of documents.

• Material breach of this Supplier Policy or the Anti-Bribery Policy (Section B).

• Insolvency, administration, or winding-up proceedings.

• Material failure to perform after a reasonable written cure period.



11. Confidentiality


All suppliers must maintain strict confidentiality regarding SNXS client information, event details, commercial terms, pricing, internal processes, and any personal data encountered during the engagement. This obligation survives termination for a period of 3 years, or the longer period specified in a signed NDA.



12. Governing Law


All supplier engagements with SNXS are governed by the laws of the United Arab Emirates and the Emirate of Dubai. Disputes are subject to the exclusive jurisdiction of the Dubai courts, or by mutual written agreement, DIAC arbitration. All SNXS supplier policies are published in English. In the event of conflict between an English and Arabic version, the English version shall prevail.



Section B — Anti-Bribery & Corruption Policy


Legal Basis: UAE Federal Law No. 11 of 2021 on Anti-Corruption; UAE Federal Decree-Law No. 31 of 2021 on Crimes and Penalties; UAE Federal Decree-Law No. 20 of 2018 on AML/CFT; UK Bribery Act 2010 where applicable; US Foreign Corrupt Practices Act (FCPA) where applicable.


Scope: Applies to all SNXS employees, directors, contractors, advisors, and all third parties acting on SNXS's behalf. Zero tolerance. No exceptions.



1. Zero Tolerance Statement


No SNXS employee, contractor, director, or representative may — directly or through any intermediary or third party — offer, pay, give, promise, request, or accept any bribe, kickback, improper payment, or corrupt advantage to or from:


• Any government official, public authority employee, or regulatory body representative in any country.

• Any private sector client, supplier, partner, or counterparty.

• Any individual in a position to influence a procurement, contracting, licensing, or regulatory decision relevant to SNXS.


This prohibition applies regardless of the amount involved, local custom or commercial practice, whether no harm appears to result, whether the purpose is merely to expedite a routine process, or whether the activity is conducted through a third party. There are no exceptions.



2. Gifts and Hospitality


Permitted — only where all of the following conditions are met:

• Value is below AED 500 per occasion (hard limit).

• Openly given in the normal course of a professional relationship.

• Not given or received with any expectation of influencing a business decision.

• Compliant with the recipient's organisation's own gifts policy.

• Recorded in the SNXS Gifts and Hospitality Register within 5 business days.


Prohibited in all circumstances:

• Cash gifts of any value to any person connected to any business decision.

• Gifts exceeding AED 500 per occasion without prior written Compliance Officer approval.

• Any gift or hospitality extended to a government official without prior written Compliance Officer approval, regardless of value.

• Gifts given at or around the time of a key procurement, contract award, or regulatory interaction.

• Repeat gifts to the same individual cumulatively exceeding AED 1,000 in any 12-month rolling period.

• Gifts in the form of cryptocurrency, digital assets, gift cards, or any transfer of value that is untraceable or difficult to record.


Gifts and Hospitality Register

All gifts and hospitality given or received with a value above AED 150 must be recorded in the SNXS Gifts and Hospitality Register within 5 business days. Each entry must state: date; description; estimated value; name and organisation of giver and recipient; and the business context. The Register is maintained by the Compliance Officer and is available for internal and regulatory audit inspection.



3. Facilitation Payments


Facilitation payments — unofficial payments to government officials or public servants intended to speed up or secure routine actions such as permits, licences, customs clearance, or inspections — are strictly prohibited regardless of the amount, local practice, urgency, or operational impact of refusal.


Any request for a facilitation payment must be refused immediately and reported to the Compliance Officer at compliance@snxs.ae. SNXS staff must not pay under any pressure or circumstance.



4. Conflicts of Interest


A conflict of interest arises where a personal financial or relational interest could improperly influence a decision made on behalf of SNXS. All SNXS personnel must:


• Not engage or recommend SNXS suppliers or partners in which they hold a personal financial interest without prior written Compliance Officer disclosure and approval.

• Not participate in procurement, contracting, or hiring decisions where a close personal or family connection exists on the counterparty side.

• Disclose in writing any outside business activity that competes with or materially affects SNXS.

• Immediately recuse themselves from any decision where an undisclosed or potential conflict exists.


Disclosure does not automatically disqualify the activity. The Compliance Officer will assess and communicate the approved handling approach in writing.



5. Third Parties and Agents


Third parties acting on SNXS's behalf — including event contractors, marketing and PR partners, influencer agents, and business development consultants — are subject to the same anti-bribery and corruption standards as SNXS staff.


SNXS will conduct AML and ethical due diligence before appointing key third-party agents, include explicit anti-bribery compliance obligations in all third-party contracts, and not knowingly engage or continue to engage any third party that has violated anti-bribery laws or this Policy.


SNXS may be held liable under UAE and international law for corrupt acts committed by third parties acting on its behalf. Due diligence and contractual protections are mandatory, not optional.



6. Sponsorships and Donations


All event sponsorships and charitable donations must be documented with a written agreement stating the commercial or charitable purpose; must not benefit any individual in a position to make decisions favourable to SNXS; and require Compliance Officer written approval for amounts above AED 10,000.


Sponsorships and donations must never be used to channel payments to government officials or to influence regulatory, licensing, or contracting decisions.



7. Reporting and Whistleblowing


Any employee, contractor, or third party who becomes aware of or reasonably suspects a violation of this Policy must report it immediately to:


Email: compliance@snxs.ae

Reports may be made anonymously.


The Compliance Officer will investigate all reports promptly, confidentially, and without prejudice.


SNXS strictly prohibits retaliation against any individual who raises a concern in good faith. Any confirmed act of retaliation — including dismissal, demotion, exclusion, or any adverse treatment — is itself a serious disciplinary offence subject to immediate action.



8. Consequences of Breach


Any confirmed breach of this Policy will result in:


• Immediate disciplinary action up to and including termination of employment or contract without notice or compensation.

• Mandatory reporting to UAE law enforcement or regulatory authorities where required by law.

• Recovery of any improperly obtained benefit or payment.

• Civil and/or criminal proceedings against the individual and, where applicable, SNXS as an entity.


UAE Penalty Reference: Under UAE Federal Law No. 11 of 2021 on Anti-Corruption, bribery of a public official carries penalties of up to 10 years' imprisonment and fines of up to AED 1,000,000. Private sector bribery carries significant criminal penalties under UAE Federal Decree-Law No. 31 of 2021 on Crimes and Penalties.



9. Training and Acknowledgement


All SNXS employees and key contractors must complete anti-bribery and compliance ethics training within 30 days of joining and annually thereafter. All personnel sign a Policy Acknowledgement on joining confirming they have read and understood this Policy. Training completion records and signed acknowledgements are maintained by the Compliance Officer and are available for audit inspection.


Failure to complete mandatory training will result in suspension from client-facing and financial processing duties pending completion.



Contact


Supplier onboarding: contact@snxs.ae

Legal matters: legal@snxs.ae

Compliance and ethics: compliance@snxs.ae

Whistleblowing: compliance@snxs.ae (anonymous reports accepted)


SkyNet X Solutions LLC FZ · Meydan Free Zone · Dubai, UAE · Licence No. 2531132.01 · www.snxs.ae

All policies incorporated by reference into every SNXS supplier contract, purchase order, and engagement letter.


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SkyNet X Solutions LLC FZ 

 

License: 2531132.01
Dubai, UAE


Dubai-based events & marketing agency for Web3, Blockchain & AI. We turn ideas and events into measurable growth.

We empower brands and creators to collaborate for meaningful value and measurable impact.

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